The scope of information to be held confidential is remarkably similar for all lawyers, no matter the country you practice in. The real differences are manifested in the exceptions to the duty of confidentiality and the applicability of the duty to in-house lawyers. The exceptions to confidentiality are generally (though not universally) broader in the United States. Do not always assume that US ethics law is the most protective. When it comes to confidential information relating to business crimes or fraud, for example, it often may not be. It is imperative to fully understand and properly analyze confidentiality and choice of law issues where foreign ethics law is involved.
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